Post-Referral Authority in Tax Litigation—IRS Lacked Authority to Approve ERC Refund
The recent decision in JPM Restaurant, LLC v. United States, case No. 1:24-cv-00357, from the United States District Court for the Eastern District of Tennessee, offers important insights for tax professionals navigating Employee Retention Credit (ERC) claims that evolve into litigation. This case highlights critical jurisdictional boundaries regarding tax liability compromises once a matter is referred to the Department of Justice (DOJ).
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